At a Glance

#1 EU Information System has an API

#2 Update on Legality guidance

#3 Interview with Naiga Doreen - EU Youth Ambassador in Uganda

#4 Leather EUDR Success

#1 EU Information System has an API!

There has been a lot of talk about the readiness of the EU’s information system in preparation for Operators to begin using it on the 31st December 2024. At the latest EUDR multi-stakeholder platform meeting, there was an updated timeline on the system, and we can confirm that an API will be available upon release!

What is an API (Application Programming Interface)? Essentially, it’s a way for two systems to talk to each other (sending data). This means that we can connect our system to the EU Information system, automating the ability to create Due Diligence Statements (DDS) and saving hours of manual data entry.

Put the 16th of December in your diaries as that is when the system will open for EU operators and traders to start creating accounts and uploading their trades.

This is big news for large operators as some consignments may have required over 1000 geolocation points, which would have created a significant administrative burden for businesses to upload all their points to the system. We will be building and testing the API to ensure the integration to our platform is working perfectly. As always, we will keep you updated on how this is progressing.

For background, the EU Information System is only to be used by EU Operators/Traders where they will upload some parts of the requested Article 9 information (product description, quantity, and geolocation data) for each trade, and sign a DDS. They will be provided with a DDS reference number which they will then attach to the consignment prior to it arriving in EU customs.

#2 Update on Legality Guidance

One of the less publicised requirements of EUDR is that companies must provide evidence that the relevant commodity has been produced in accordance with the relevant legislation of the country of production.

The legality documentation covers the following areas: land use rights, environmental protection, forest-related rules, third parties’ rights (i.e. local communities), labour and human rights, the principle of Free, Prior, and Informed Consent (FPIC), and relevant tax, anti-corruption, trade and customs regulation. Article 2(40) points (a-h)

The obligation is to provide evidence for the above, including official documents such as land titles, certification scheme material, judicial decisions showing the appropriate enforcement of the legalisation, and any impact assessments, management plans, or environmental audit plans. In addition, any company policies, codes of conduct, and social responsibility agreements can further reduce the consignment’s risk profile.

Providing a comprehensive package of legal evidence to prove that the commodity was grown following the laws of the area of production will reduce the risk of non-compliance with the EUDR legality requirement.

#3 Interview with Naiga Doreen

We had the pleasure of interviewing Naiga Doreen a couple of weeks ago, who is a lawyer by profession and a member of the European Union Youth Sounding Board based in Uganda. She recently sat down with the EU Environment Commissioner Mr Virginijus Sinkevičius to discuss all things EUDR.

A few highlights of our exchange with Naiga were:

  • She was raised in a rural part of Uganda and started to notice fewer and fewer fruit trees as she grew up, which made her reflect on the startling degradation of nature and biodiversity, igniting her passion for tackling climate change
  • Agricultural expansion is an important part of the Uganda smallholder community and livelihoods. With EUDR being implemented, there are hard decisions to make for farmers on the ground in terms of protecting nature but also feeding their families. More funding and incentives are needed to protect smallholder farmers and their income.
  • There is currently a lot of complexity within EUDR as well as a lack of awareness which is creating slower adoption at the smallholder farmer level. Naiga is herself taking the lead and speaking on radio shows and other local events to build awareness to prepare farmers for this significant supply chain shock
  • Land issues are a big challenge in Uganda, and geolocation data may cause pushback from farmers who are very protective of their land.
  • Regenerative agriculture practices need to be a higher priority if we are going to ensure the social impact of EUDR implementation is minimal. Most people will not look to protect forests if they cannot feed themselves.

It’s very important to keep the discussion on the impact of EUDR on smallholder farmers continuing. Thanks to Naiga for taking the time to speak to us and for her work with the European Union Youth Sounding Board.

#4 Leather EUDR Success

In response to questions from Cotance, the EU recently stated that “traceability activities, in the case of hides, may be done by batch”. This clarification on the geolocation requirements for cattle hides should reduce the administrative burden for tanneries when complying with EUDR for their shipments into and out of the European Union.